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May 15, 2026

Article 165 provides the formula for calculating 'disputed tax'. It is defined as the mathematical difference between the total tax due as per the contested assessment and the tax that would be due on the portion of income that has NOT been objected to. Effectively, this Article isolates the tax liability associated solely with the contested items. This calculation is essential for determining how much tax the taxpayer must pay immediately (the undisputed part) versus how much they can legally apply to postpone under Article 162.

Part 6 - Tax Disputes

Chapter 1 - Objection

Section 3 - Postponement of Payment of the Objected Tax

Article 165

[GTL Notes: Determination of Disputed Tax]

In determining the tax in dispute, the amount of objected tax shall be the difference between the amount tax due as per the assessment, and the amount of tax due on that part of the taxable income that has not been objected, as if such income is the taxable income for that tax year.